“This is the opening shot in a new battle with Google, Nickelodeon, Amazon, Netflix, Cartoon Network and others that are trying to cash in on this generation of young children,” said Jeff Chester, director of the Center for Digital Democracy. “It’s a battle for the hearts and minds and pocketbooks of America’s kids in the digital age.”

Google has said its new kid-centric video service is its first product built “with little ones in mind.” But the new mobile app has angered an influential group of psychologists and consumer advocates including Chester, who in the late 1990s helped win a national campaign to protect children’s online privacy.

Their complaint accuses YouTube Kids of mixing commercial content with children’s video programming using practices banned on broadcast and cable television by another agency, the Federal Communications Commission. Those restrictions — such as banning children’s TV hosts or cartoon characters from hawking products during a show — emerged in the 1970s in response to research showing young children have not developed the cognitive skills to resist advertising or understand they are being targeted.

“Google simply ignored the basics,” Chester said. “They deliberately ignored the well-documented research on children’s developmental limitations when it comes to advertising and programming.”

In a statement, a YouTube spokesperson said, “When developing YouTube Kids we consulted with numerous partners and child advocacy and privacy groups. We are always open to feedback on ways to improve the app.”

Georgetown Law School’s Institute for Public Representation drafted the letter on behalf of the Campaign for a Commercial-Free Childhood, Consumer Federation of America, Center for Science in the Public Interest, Children Now, American Academy of Child and Adolescent Psychiatry, Consumer Watchdog, Corporate Accountability International, Public Citizen and the Center for Digital Democracy. The nation’s largest consumer advocate, Consumers Union, became the 10th organization to sign on to the complaint Monday.

This newspaper was first to report about advocates’ concerns about advertising and product placement on YouTube Kids after Google introduced the app in late February on Apple and Android mobile devices. At the time, Google said it included advertising so that it could make the service free. The company also said its own internal policy team would only allow commercials it deemed family-friendly.

Indeed, many of the 30-second or 60-second ads that can be found on the app are public service announcements promoting the U.S. Forest Service’s outdoors campaign and other civic messages. But others promote toys or entertainment brands.

It’s not just the traditional commercials that bother consumer advocates, who are also setting their sights on the app’s branded channels for McDonald’s, Lego or My Little Pony where cartoon shows blur into videos that resemble lengthy product promotions. The complaint also asks the FTC to probe the murky world of “unboxing” videos — a popular trend in which YouTube users upload amateur home videos of themselves opening toy packages and showcasing products.

“We want Google to pull all of its unboxing videos from the app,” Chester said. “There’s no disclosure of who actually owns those channels. They’re an ad, in essence, for toys.”

Other advocates who are supporters of YouTube Kids dismissed the complaint as overreaction.

“I like it a lot and it’s free, so if it’s free, something’s got to pay for it,” said Parry Aftab, an Internet privacy lawyer who is also executive director of Virginia-based WiredSafety. “We are the United States. We are an ad-driven nation.”

Aftab was one of a handful of advocates asked by Google to view the app before its launch. Aftab’s endorsement appeared with Google’s original announcement.

She said she doesn’t remember seeing any commercials, but said Monday, “I don’t worry about ads as long as they’re not ads for Viagra and Victoria’s Secret and things like that, and as long as you teach your kids the reality of ads.”

Advertising-fueled Web companies such as Google have long had an interest in appealing to children who are increasingly being entertained and educated on mobile devices but have had to tread carefully because of regulatory safeguards.

“Their revenues, their growth is declining because of the move to mobile and reduction in revenues on search,” Chester said. “Facebook is hot on their heels. So they decided to better monetize kids, and to do it as early as possible in order to build revenues they desperately need.”

The coalition’s complaint argues that the app violates Section 5 of the Federal Trade Commission Act prohibiting unfair and deceptive marketing. FTC investigations are confidential unless the agency files a complaint or consent decree, said Angela Campbell, a law professor who wrote the complaint and directs Georgetown’s Institute for Public Representation. The commission can also informally negotiate with a company to make changes.

“I think they’ll take it very seriously. These are very serious claims,” she said. “They could subpoena info about how the algorithms work and who the sponsors are. Or Google could stop doing this and it would go away.”

The complaint to be filed Tuesday asks the FTC to investigate several features of YouTube Kids:

Branded channels: “McDonald’s has its own channel on YouTube Kids … (presenting) promotional videos styled as news reports on topics such as, ‘What are McDonald’s McNuggets made of?’ … (Branded channels) take advantage of children because they do not understand that the entire channel is actually advertising.”

Lack of separation between shows and ads: “Selecting My Little Pony brings up four options. Two of the four options are labeled ‘TV Commercial.’ The other two are identified as ‘TV Clip’ but are actually promotions for the My Little Pony program.’ “

User-generated unboxing videos: “McDonald’s Happy Meal Surprise Egg!” is a 7:41 minute video that “shows a woman opening a giant egg decorated with the McDonald’s double arches to reveal Happy Meal toys inside. The video features children’s background music and includes dolls from Disney’s Frozen movie enjoying an ice cream sundae and a Sprite in a McDonald’s cup. … The video is in effect a seven-minute commercial.”

A series of reports this year by researchers and media have drawn attention to the loose movement and its propagation on social media. In April, an advocacy group called the Tech Transparency Project warned that Boogaloo followers were discussing taking up arms while promoting protests to "liberate" states from coronavirus restrictions.